Using forms which failed to include a comprehensive grievance and appeals process, which did not provide coverage for newborn care equivalent to mother’s, which failed to provide coverage for mammograms. and for plans that covered hospital and medical care which failed to provide coverage for chemical dependency.

Use of unfiled forms, issuing blanket coverage to groups which did not meet the requirements necessary to qualify for blanket coverage, providing disability coverage to individuals in Washington under a group policy delivered to policyholders outside of Washington.